The Chartered Institute of Housing (CIH) is calling for more powers in response to a consultation
The call for more energy efficiency enforcement powers comes as the CIH’s response to the Department for Energy Security and Net Zero’s (DESNZ) consultation on improving energy performance in privately rented homes.
The CIH mostly agree with the DESNZ consultation’s proposals, saying they will help ensure warm, safe, and more affordably powered homes.
The CIH feels more energy efficiency enforcement is crucial for councils
In their response to the consultation, the CIH states that more capacity must be given to local authorities to ensure energy efficiency enforcement and regulations are complied with. While some steps have been taken already, CIH feels that more must be done to achieve the proposed standards.
CIH policy manager, Matthew Scott, said: “Private renters are far more likely to live in homes that are cold and unaffordable to heat, with over a fifth of all private renters living in fuel poverty. CIH warmly welcomes the proposed introduction of minimum energy efficiency standards in the private rented sector, which we have advocated for across many years.
“To ensure the proposals are successful, it is vital that local authorities are provided with the funding they need to proactively enforce the standards. For the vast majority of good private landlords, enforcement will not be necessary, but it is important that local authorities are fully resourced to act where it is needed.”
CIH listed six additional points for the consultation
The points of consideration are as follows:
Enforcement
As the professional body for people who work in housing, CIH has many members working in local authority housing departments. Members have expressed concerns that without adequate funding, it will be very challenging to enforce these new standards. CIH strongly welcomes the action the new government has taken to put local authority finances on a more stable footing, but this is unlikely to be sufficient to ensure enforcement of the regulations can be properly resourced.
The government must ensure that local authorities are provided with the long-term, ring-fenced funding they require to enforce the new standards. This will enable local authorities to undertake proactive enforcement of the standards, which will discourage non-compliance.
More generally, we support the proposals of other charities, consumer groups, and climate groups to increase enforcement and compliance actions, such as those proposed by E3G and the National Retrofit Hub.
Skills and the supply chain
If minimum energy efficiency standards are introduced in both rented sectors with a compliance target of 2030, this will place pressure on the supply chain for retrofit. The wider construction sector is facing acute and ongoing challenges due to Brexit and the Covid-19 pandemic, and construction sector capacity must be sufficient to cope with the demand placed on it by all building services and asset management work, not just retrofitting homes.
We have also received feedback from CIH members that social landlords have experienced challenges securing maintenance and servicing contracts for renewable and low-carbon heating technologies, especially solar PV and heat pumps. These contracts cannot be fulfilled by the existing workforce (e.g. gas heating engineers without sufficient heat pump training) without upskilling. The market for maintenance and servicing will therefore need to grow considerably in the coming years if more installations of smart technologies and low-carbon heating are driven by the government’s proposed approach to regulation in the rented sectors.
This evidence suggests that the government needs to ensure that the various supply chains for retrofit, servicing, and maintenance are supported to meet increased demand. To achieve this, we support the detailed recommendations made in the Chartered Institute of Building’s manifesto for the built environment, such as the creation of a holistic Green Skills Fund, actions to tackle late payment culture, and the use of geographical clustering to boost the construction workforce across the UK.
Protections for renters
We share the view of other charities, consumer groups, and climate groups that the Renters’ Rights Bill could be strengthened to provide sufficient protection for renters.
CIH members have raised concerns that without additional protections, private landlords may increase rents either pre- or post-improvements and present this as the only way they can afford to meet the standard. This is despite evidence suggesting that many landlords have the required capital to make improvements, or can borrow against the value of their home (especially in parts of the country with high house prices). If rent increases occur, more renters may be evicted due to non-payment, which could place additional pressure on already stretched local authority homelessness duties.
Funding for landlords
There are clearly going to be circumstances where some private landlords will struggle to afford the cost of energy performance upgrades. This may be because they have limited access to capital or may struggle to borrow against the value of their home because of its low market value.
This latter barrier may particularly be the case in parts of the country with persistently low house prices. Outside of London, some of the former housing market renewal pathfinder areas now have high proportions of private rented homes, and there are other large concentrations of private rented homes with depressed values in other areas of the country.
The government should consider how a mixture of financial incentives, such as grants (e.g. through the Warm Homes: Local Grant scheme), tax incentives, and low/no interest loans could be utilised to support private landlords to make the necessary energy performance upgrades. These measures should be targeted at private landlords that might otherwise find it difficult to afford the cost of energy performance upgrades, to ensure that public money and incentives do not unnecessarily pay for work that landlords could afford to carry out themselves.
Advice and support
CIH believes that energy advice for both tenants and landlords is crucial and should be seen as a more central part of improving energy performance in the private rented sector.
The proposed approach to regulation implies that landlords and tenants will need to understand sometimes complex forms of smart technology and low-carbon heating. Landlords will need to select the appropriate measures from a wide market of possible products, and tenants will need to properly understand how to use these products if they are to access the energy bill savings and other benefits that they promise. Some tenants will also need to be supported with complex, disruptive retrofits, including instances where they may need to temporarily move out of the home to ensure intrusive works can be properly undertaken.
The government should examine how to improve the provision of energy and retrofit advice for private landlords and tenants. This should include action to ensure private landlords are aware of the regulation and can meet their obligations by the proposed deadlines. It should also include the production of guidance for tenants.
Consumer protection
Lastly, the government must ensure that all measures installed in privately rented homes are completed to a high standard by competent, qualified installers. Installations should be carried out in adherence to appropriate standards (e.g. MCS and, where necessary, PAS2035) with clear pathways for redress for both tenants and landlords. We welcome the government’s stated intention to reform the existing system of protections for consumers as part of its Warm Homes Plan.
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